Global Labor Law Weekly: UK, EU, US & APAC

During the week of September 28 – October 4, 2026, the global direction of labor law was unmistakable: UK employer duties are expanding, EU pay transparency is accelerating, and the US is loosening at the federal level while tightening at the state level. The UK's Employment Rights Act 2025 entered a new phase, bringing the trade-union information duty, upgraded anti-harassment duties, an extension of tribunal time limits and expanded right-to-work liability. In the EU, Slovakia became the first member state to complete transposition of the Pay Transparency Directive, with Greece and Malta following. In the US, the Senate confirmed a new Labor Secretary while the DOL advanced overtime and independent-contractor rulemaking.

For HR and employers running cross-border operations, none of this is "news" — it is a to-do list. Here is the breakdown by region.

1. The Week at a Glance

Three things to act on now: first, the UK's October trade-union information duty and anti-harassment duties; second, the transposition of the EU Pay Transparency Directive in Slovakia, Greece and Malta; third, California's 2027 employment law package and New York's personnel-file access law.

2. Europe

2.1 [UK] UK: Employment Rights Act 2025 — New October Phase

The UK's Employment Rights Act 2025 has entered another phase of commencement. According to Lewis Silkin's Employment Rights Act timeline, four changes took effect this month:

① Trade-union information duty. Employers must proactively inform workers of their right to join a union, alongside adjustments to access and recognition rules. ② Upgraded harassment-prevention duty. Employers must take "all reasonable steps" to prevent harassment, emphasizing prevention over reaction — including third-party scenarios (clients, suppliers, contractors). ③ Longer tribunal time limits. Most claims now carry a six-month deadline instead of three months, extending the employer's response window and evidence-retention obligations. ④ Expanded right-to-work liability. From October 1, civil-penalty liability for non-compliant hiring extends across a wider set of organisations and commercial arrangements.

For Chinese-owned entities with a UK presence, this means refreshing policies, training, complaint channels and investigation records across the whole hire-to-exit cycle within a quarter.

2.2 [EU] EU Pay Transparency Directive: Slovakia Leads, Greece and Malta Follow

Per Trusaic's member-state transposition monitor, the EU Pay Transparency Directive required member states to transpose it into national law by 7 June 2026 to close the EU's 12.7% gender pay gap. So far only Slovakia, Italy, Lithuania and Malta met the deadline; this week Slovakia became the first to announce completion, with Greece and Malta following, while the remaining 23 states continue.

Under Directive 2023/970, the core mechanics are broadly consistent: pay ranges in job ads; no questions about salary history; no pay-confidentiality clauses; an employee right to pay information; and gender pay-gap reporting, with a joint pay assessment triggered when the gap for equal work exceeds 5%. Italy's transposition differs from the baseline in several respects, so employers should model its local rules separately.

2.3 [NL][DE] Netherlands, Germany and Czechia: Time, Gig Work and Self-Employment

The Netherlands published its Q3 2026 employment-law insights and will implement working-time registration (tijdsregistratie) requirements from 2027, requiring timekeeping systems to be upgraded. In Germany, Amazon warehouse workers continue organising for "every minute paid," while the status of volunteers under employment law draws attention. Czechia may revise its controversial "Švarc system" (self-employment outsourcing), reshaping tax and social-security responsibility for freelancers and their engagers.

3. Americas

3.1 [US] US Federal: New Labor Secretary; Overtime and Independent-Contractor Rules Advance

The Senate confirmed Keith Sonderling as Labor Secretary by 47–41, signalling an employer-friendly DOL. Federal actions this week included a proposed revision of the overtime exemption threshold for salaried white-collar workers; the independent-contractor rule entering final review, pointing toward an easier employee-classification threshold; and the NLRB returning to an employer-friendly standard for disciplining workplace misconduct, while its General Counsel called for reversing the unilateral-change standard.

3.2 [US] California: The 2027 Employment Law Package

Governor Newsom signed and vetoed a batch of bills in his final year, with a package taking effect in 2027. Highlights: the farmworker minimum wage rising toward $19.75/hour; workplace surveillance and restroom privacy restrictions; strengthened AI protections for workers in hiring, termination and performance evaluation; and bereavement leave expanding the "family member" definition to include a designated person. In addition, the AB 1697 "Stay or Pay" rule was delayed to 1 January 2027 with expanded exceptions.

3.3 [US] New York: Personnel-File Access and Three New Protections

New York's personnel-file access law takes effect on 8 November 2026, giving current and former employees the right to inspect, review and challenge their personnel records, with hard requirements on record scope, retention and response times. Three further New York labour protections took effect on 1 October. Employers should Inventory record types and retention periods, and set response and adverse-information notice workflows.

3.4 [US] US Minimum Wage and State Rules (2026–2027)

Washington's thresholds are published by the state Department of Labor & Industries (L&I). New Jersey's contested ABC independent-contractor test rules took effect on 1 October 2026.

3.5 [CA][MX] Canada, Mexico and Costa Rica

Ontario announced a minimum-wage increase to protect workers and support a competitive economy. Mexico's workweek reduction approaches, yet only 18% of companies say they are ready. Costa Rica's new workplace harassment standard took effect on 1 October 2026. See Ontario's Employment Standards Act.

4. Asia-Pacific

4.1 [JP] Japan: Anti-Customer Harassment Rules Take Effect; Residency Fees Soar

According to NHK World-Japan, Japan's new rules on customer/third-party harassment (kasuhara) took effect on 1 October 2026, requiring employers to protect staff from harassment by clients and third parties — another expansion of employer protection duties after "power harassment." Japan also sharply raised foreign residency fees and tightened some rules, directly affecting expatriate cost and compliance, while harassment of jobseekers draws growing scrutiny.

4.2 [KR] Korea: Occupational Safety and Health Act Amendment Passed

Korea's National Assembly passed more than 60 bills, including an amendment to the Occupational Safety and Health Act imposing a fine of up to 5% of operating profit on companies that repeatedly cause serious industrial accidents. Labour inspectors, meanwhile, face surging lawsuits and complaints. Per Korea's Ministry of Employment and Labor (MOEL), high-risk manufacturing, construction and logistics employers should strengthen safety systems and incident review.

4.3 Southeast and South Asia

Vietnam's gig workers are finding new ways to push back as platform-work status and protection debates continue. Malaysia's RM2,000 minimum wage hinges on the 2027 budget (the current floor remains RM1,700/month). About half of Singapore employers use AI in hiring. Firms also flag the hidden legal risks of cross-border remote work in Southeast Asia (permanent establishment, tax and employment-law application), while Bangladesh discusses safe migration and labour-law reform.

5. Middle East & Africa

Saudi Arabia recorded 11,819 residency, labour and border violations in a single week, underscoring intensifying enforcement — employers should ensure work permits, iqama and visa status all align. Egypt's cabinet suspended its earlier Sunday remote-work decision, reversing course on flexibility. In Kenya, a report exposed traffickers targeting children for sexual exploitation, labour and crime, keeping labour-migration and supply-chain due diligence in focus.

6. Five Signals for the Week

Next week: official UK guidance for the commenced ERA 2025 provisions; more EU member states publishing pay-transparency transposition texts; DOL consultations and final forms for the overtime and independent-contractor rules; implementing details for California's 2027 laws; and the effective date and penalty standards for Korea's OSHA amendment.

* This article is for informational purposes only and does not constitute legal advice.